The Question · Physical therapy · MIPS
Traditional MIPS has an end date. PT practices need a pathway plan now.
Physical therapists are MIPS eligible clinicians, and many practices sit right on the low-volume line. CMS has proposed ending traditional MIPS after 2028 and replacing the main PT functional status measures in 2027. Here is who must report, what the score costs, and what changes.
By ASP-RCM Editorial, Healthcare RCM Practice · Updated
The question we asked on LinkedIn
CMS proposes ending traditional MIPS after 2028. If your PT practice sits near the low-volume line, do you opt in and build the data now, or stay out and pay later?
Points to avoid a penalty
MIPS performance threshold, finalized through the 2028 performance period
Maximum negative adjustment
A 2026 final score of 18.75 points or less gets the full -9% in the 2028 payment year
Low-volume line, plus 200 and 200
Required to report only if you exceed $90,000 in Part B charges, 200 patients and 200 services
MVP-only year, proposed
CMS proposes MVPs as the only MIPS option outside MIPS APMs from the 2029 performance period
Are you required to report?
CMS checks each TIN and TIN/NPI combination against three low-volume tests for the performance year.
| Your Medicare Part B volume | Status | What it means |
|---|---|---|
| Exceeds all three: more than $90,000, 200 patients and 200 services | MIPS eligible | Required to report. Individually eligible clinicians get a payment adjustment even if no data is sent. |
| Exceeds one or two of the three | Opt-in eligible | May opt in for a real score and adjustment, report voluntarily, or do nothing. |
| Exceeds none | Exempt | No adjustment. May still report traditional MIPS voluntarily for feedback. |
| First enrolled in Medicare on or after January 1, 2026 | Excluded for 2026 | Not eligible for a 2026 MIPS payment adjustment. |
Source: CMS QPP, How is Eligibility Determined, 2026 performance year. Eligibility is reviewed in two 12-month segments, so status can change by the final determination in December.
From traditional MIPS to MVPs
2026 rules are final. 2027 and later items are proposed in the CY 2027 rule; the final rule had not been published as of November 4, 2026.
- 2026
Performance year scored against 75 points; the result sets your 2028 Medicare payment adjustment.
- Dec 2026
Final 2026 eligibility determination released.
- 2027
Proposed: Rehabilitative Support for Musculoskeletal Care MVP renamed Rehabilitative Support MVP; seven PT functional status measures replaced.
- 2028
Proposed last performance year for traditional MIPS. Threshold stays at 75.
- 2029
Proposed: MVPs become the only MIPS option for clinicians not in a MIPS APM.
The PT outcome measures CMS proposes to swap in 2027
CMS proposes removing seven functional status change measures and adding five patient-reported outcome performance measures that use PROMIS tools or a legacy tool.
Proposed for removal
- Q217 knee, Q218 hip, Q219 lower leg, foot or ankle
- Q220 low back, Q221 shoulder
- Q222 elbow, wrist or hand
- Q478 neck
Proposed new measures
- Knee (PROMIS Physical Function or Knee Outcome Survey)
- Lower extremity, not knee (PROMIS Physical Function or LEFS)
- Back (PROMIS Pain Interference or Modified Low Back Disability Questionnaire)
- Upper extremity (PROMIS Upper Extremity or QuickDASH)
- Neck (PROMIS Pain Interference or Neck Disability Index)
Other proposals PT owners should read
MIPS core measure
Proposed: one quality measure must be a MIPS core measure, 1 of 6 in traditional MIPS or 1 of 4 in an MVP. Small practices are exempt.
Eligibility is per TIN/NPI
A PT who reassigns billing to two practices is checked twice. Each combination can land in a different status.
Opt-in data is public
Opt in and your score is real: positive, neutral or negative, and published on Care Compare.
A MIPS plan for a PT practice
Check status
Look up each TIN and NPI on the QPP eligibility tool. Note preliminary and final results.
Pick the pathway
Traditional MIPS through 2028, or the Rehabilitative Support MVP now while it is optional.
Build outcome data
Collect the same patient-reported tool at intake and discharge for every episode in scope.
Report and review
Submit, then read the feedback report. Fix data gaps before the next performance year.
Is your practice ready for the MVP years?
Tick what is true today.
Check status per TIN and NPI, protect the 75-point line in 2026, and start collecting patient-reported outcomes on the proposed tools in 2027. The proposed MVP-only year is 2029, so a two-year build is the safe path.
Questions operators ask next
Do physical therapists have to participate in MIPS?
Only if they are MIPS eligible. Physical therapists are an eligible clinician type, but a PT or practice must exceed all three low-volume tests: more than $90,000 in Medicare Part B covered professional services, more than 200 Part B patients and more than 200 covered services. Exceeding one or two makes you opt-in eligible.
What MIPS score does a PT need in 2026?
The performance threshold is 75 points, finalized through the 2028 performance period. A 2026 score of exactly 75 gives a neutral adjustment in 2028. Scores of 18.75 or less get the maximum -9%. Scores above 75 get a positive adjustment, scaled for budget neutrality.
Is traditional MIPS ending?
CMS proposed in the CY 2027 Physician Fee Schedule rule to sunset traditional MIPS after the 2028 performance period. From 2029, MVPs would be the only MIPS option for clinicians not in a MIPS APM. This is a proposal; the final rule had not been published as of November 4, 2026.
Which MVP fits physical therapists?
The Rehabilitative Support for Musculoskeletal Care MVP, which CMS proposes to rename the Rehabilitative Support MVP for 2027. CMS also proposes replacing seven functional status measures (Q217 to Q222 and Q478) with five patient-reported outcome measures that accept PROMIS tools or named legacy tools.
Want to know where your PT practice stands on MIPS?
Send us your Medicare Part B volume and last MIPS feedback. A senior therapy billing partner checks eligibility by TIN and NPI, flags payment-adjustment risk, and sends a written plan after a free 30-minute call.
Keep reading
Sources
- CMS QPP, How is Eligibility Determined, 2026 performance year
- CMS, 2026 QPP Final Rule Fact Sheet and Policy Comparison Table
- CMS, CY 2027 PFS Proposed Rule: QPP Fact Sheet and Policy Comparison Table
- CMS, Proposed Timeline: Transitioning from Traditional MIPS to MVPs
- Federal Register, CY 2027 Physician Fee Schedule proposed rule, July 16, 2026
Checked November 4, 2026. 2027 and later items are proposals from the CY 2027 PFS proposed rule and may change in the final rule. Confirm your eligibility on the QPP site. General information, not legal advice.